Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent has determined a deficiency in petitioner's income tax liability for the year 1939 in the sum of $274.06. This deficiency results from respondent's inclusion in petitioner's gross income for the taxable year of $1,191.49 which he explains in his notice of deficiency as income received by petitioner from the estate of the latter's deceased wife and taxable to him pursuant to section 162 (c) of...
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